Epstein Secrets

overnment which may be favorable to the defendant on the issues of guilty or punishment within the scope of Brady. Maryland, 373 U.S. 83 (1963), and United Stales, Agurs, 427 U.S. 97 (1976)." See, e.g., Standing Discovery Order, United States' Enriquez, No. 1:10-CR-20488- MGC (July 9, 2010) (doc. #115). These

/21/2011 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOE #1 and JANDE DOE #2 I. UNITED STATES JANE DOE #1 AND JANE DOE #2'S MOTION TO USE CORRESPONDENCE TO PROVE VIOLATIONS OF THE CRIME VICTIMS' RIGHT ACT AND TO HAVE THEIR UNREDACTED PLEADI

ners argue that the Court should accept their Statement as true, despite its conclusory allegations and internal inconsistencies, solely because of the United States' failure to stipulate to the Statement. The Court should deny the motion because: (1) Petitioners have misstated that United States' efforts at reach

respond to the victims' motion for a finding of violation of the CVRA is untimely, as that is when the victims must begin drafting reply pleadings. See United States! Jefferson County, 720 F.2d 1511, 1516 (nth Cir. 1983) (listing factors to be considered in determining whether motion to intervene is timely). CERT

6) ("Nothing in this chapter shall be construed to impair the prosecutorial discretion of the Attorney General or any officer under his direction"); Waytel United States, 470 U.S. 598, 607-08 (1985) (the decision whether to prosecute is "particularly ill-suited to judicial review," and "not readily susceptible to th

ship that Prince Andrew, 51, fourth in line for the throne, has maintained with the multimillionaire, a registered sex offender [Jeffrey Epstein)." Jose Lambiet, Prince's Friendship with Pedophile Causes Furor Across the Pond, PALM BEACH POST, Mar. 9, 2011, at 2B. There are also current reports that the FBI

ve who Markus said called Muentes repeatedly and steered him toward an underage prostitute. CI) Holy Cross p Hos ital 2" Year in a row <J4, ‘s, AMERICAS 50 BEST HOSPITALS But prosecutors insisted Muentes made the choice to request a teenager without encouragement and took concrete steps toward act

sraelis bag past when Arab fighters would see the advancing Israeli army, dis- card their boots and flee in terror. The strategy of Israel's (and Americab) enemies today is to lure the military superpower into a pro- tracted conflict 'lb accept the bait, as the Israelis did in assaulting Leb- anon and

hattan home address. ached by telephone, she dieclii~pstein. ■ 23, whose fam- ily in ugos via ps in paid money to so that he could bring her to the United States to be his "sex slave," two teenage - tikrthlkat. -LE S-Cirtunk- I cloy -Sivt Is Icovk -1 351N feillo -1 • • • girls told police. One gir th

er • OJ. Simpson?) and Kenneth Starr (remember Monica Lewinsky?). Jack Goldberger of West Palm Beach, who also on the team, told Post columnist Jose Lambiet in November: "This case is absolutely • going to end without a trial within the next two months." He was wrong, but Mr. Gold- berger remains on M

3/21/2011 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johason JANE DOE #1 and JANE DOE #2 I. UNITED STATES JANE DOE #1 AND JANE DOE #2'S MOTION TO HAVE THEIR FACTS ACCEPTED BECAUSE OF THE GOVERNMENT'S FAILURE TO CONTEST ANY OF THE FACTS COME NOW Jane Do

11 Page 1 of 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 08-80736-Civ-Marra/Johnson JANE DOES #1 AND #2, Petitioners, I. UNITED STATES OF AMERICA, Respondent. UNITED STATES' RESPONSE TO PETITIONERS' MOTION TO USE CORRESPONDENCE TO PROVE VIOLATIONS OF THE CRIME VICTIMS' RIGHTS ACT AND TO HAV

ners argue that the Court should accept their Statement as true, despite its conclusory allegations and internal inconsistencies, solely because of the United States' failure to stipulate to the Statement. The Court should deny the motion because: (1) Petitioners have misstated that United States' efforts at reach

ship that Prince Andrew, 51, fourth in line for the throne, has maintained with the multimillionaire, a registered sex offender [Jeffrey Epstein]." Jose Lambiet, Prince's Friendship with Pedophile Causes Furor Across the Pond, PALM BEACH POST, Mar. 9, 2011, at 2B. There are also current reports that the FBI

minal sentences" to reject mandamus under the Act where a defendant had pleaded guilty and had been sentenced more than two years earlier); see also United States v. Bedonie, 413 F.3d 1126, 1129-30 (10th Cir. 2005) (district court had no authority under mandatory restitution act to reopen restitution proceedin

1 and Jane Doe 2 can have no legitimate particularized need for grand jury materials that they intend to use in violation of the rules of evidence. See United States v. Capozzi, 486 F.3d 711, 727 (1st Cir. 2007) (no right to grand jury transcripts established by defendant who sought them to substantiate an appea

information. First, their stated strategy is to spread these letters among media outlets such as the television show Law and Order, gossip columnist Jose Lambiet of the Palm Beach Post, and the British media, which Jane Doe 1 and Jane Doe 2 state has "gone berserk" with gossip about Mr. Epstein. [DE 51 at 7]

fic discussion of the CVRA and victim notices. All relevant evidence is admissible. See Fed. R. Evid. 402. Relevant evidence is "broadly defined," United States' Glasser, 773 F.2d 1553, 1560 (11th Cir. 1985), as evidence that has "any tendency to make the existence of any fact that is of consequence to the d

ship that Prince Andrew, 51, fourth in line for the throne, has maintained with the multimillionaire, a registered sex offender [Jeffrey Epstein]." Jose Lambiet, Prince's Friendship with Pedophile Causes Furor Across the Pond, PALM BEACH POST, Mar. 9, 2011, at 2B. There are also current reports that the FBI

Circuit has instructed that the district courts must make substantial findings before sealing records in criminal cases before it. For instance, in United States'. Ochoa-Vasque, 428 F.3d 1015 (11ih Cir. 2005), the Eleventh Circuit reversed an order from this Court that had sealed pleadings in a criminal case,

/www.ft.com/cms/s/0/78dba2c2-b383-11e0-b56c- 00144feabdc0.html#axzz31RjOpH61. The American media, too, has commented on these relations. See, e.g., Jose Lambiet, Prince's Friendship with Pedophile Causes Furor Across the Pond, PALM BEACH POST, Mar. 9, 2011, at 2B. In light of all this interest, it appears t

r showing of a `substantial case on the merits when the balance of the equities weighs heavily in favor of granting the stay.'" DE 206 at 2 (citing United States' Hamilton, 963 F.2d 322 (11th Cir. 1992) (internal quotations omitted)). Citing relevant caselaw, the district court found that Epstein had "neither

ship that Prince Andrew, 51, fourth in line for the throne, has maintained with the multimillionaire, a registered sex offender [Jeffrey Epstein]." Jose Lambiet, Prince's Friendship with Pedophile Causes Furor Across the Pond, Palm Beach Post, Mar. 9, 2011, at 2B. 18 EFTA00209525 proceedings continue be

fic discussion of the CVRA and victim notices. All relevant evidence is admissible. See Fed. R. Evid. 402. Relevant evidence is "broadly defined," United States' Glasser, 773 F.2d 1553, 1560 (11th Cir. 1985), as evidence that has "any tendency to make the existence of any fact that is of consequence to the d

ship that Prince Andrew, 51, fourth in line for the throne, has maintained with the multimillionaire, a registered sex offender [Jeffrey Epstein]." Jose Lambiet, Prince's Friendship with Pedophile Causes Furor Across the Pond, PALM BEACH POST, Mar. 9, 2011, at 2B. There are also current reports that the FBI

fic discussion of the CVRA and victim notices. All relevant evidence is admissible. See Fed. R. Evid. 402. Relevant evidence is "broadly defined," United States' Glasser, 773 F.2d 1553, 1560 (11th Cir. 1985), as evidence that has "any tendency to make the existence of any fact that is of consequence to the d

ship that Prince Andrew, 51, fourth in line for the throne, has maintained with the multimillionaire, a registered sex offender [Jeffrey Epstein]." Jose Lambiet, Prince's Friendship with Pedophile Causes Furor Across the Pond, PALM BEACH POST, Mar. 9, 2011, at 2B. There are also current reports that the FBI

l wrangling, Mr. Epstein pleaded guilty to lesser state charges. Upon his release from jail, he must register as a sex offender wherever he goes in the United States. People from all walks of life break the law, of course. But for the rich, wrapped in a cocoon of immense comfort, it can be easy to yield to tempt

ed to keep synagogues from opening. There are now four on the little island, including an Orthodox shul started by Slim-Fast founder Danny Abraham. Jose Lambiet, gossip columnist for the Palm Beach Post, says, "Half my sources on the island are Jewish socialites." Lambiet says the case has fed rage within t